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Privacy Policy

Introduction

Deconflict, Inc. (“Deconflict,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information of those who interact with our Services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you access our crypto wallet intelligence platform and related services (collectively, the “Services”).

This Privacy Policy applies to law enforcement agencies, financial institutions, cryptocurrency exchanges, fintech companies, and other verified users (“you” or “users”) who register for and use our Services.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.

1. Scope and Application

1.1 What This Policy Covers

This Privacy Policy applies to personal information we collect through:

Our website at deconflict.com

Our web-based application and dashboard

Our API services

Email and other communications with us

Registration and account management processes

1.2 What This Policy Does Not Cover

This Privacy Policy does not apply to:

Information processed on behalf of our customers: When law enforcement agencies or other customers submit crypto wallet data to our platform, we act as a service provider processing that data according to our Terms of Service and contracts with those customers, not under this Privacy Policy.

Third-party websites or services: Our Services may contain links to third-party websites or services that have their own privacy policies. We are not responsible for the privacy practices of these third parties.

Employee or job applicant data: Information about Deconflict employees and job applicants is covered under separate internal policies.

1.3 Important Distinction: User Data vs. Submitted Wallet Data

User Personal Information (covered by this Privacy Policy): Information about you as a registered user of our platform, including your name, email address, organization, and account credentials.

Submitted Wallet Intelligence (not covered by this Privacy Policy): Crypto wallet addresses, risk indicators, and related intelligence submitted by law enforcement agencies and other verified users. This data is processed under our Terms of Service and customer contracts, and does not contain personally identifiable information about suspects, victims, or investigation subjects.

2. Information We Collect

The information we collect depends on how you interact with our Services and the requirements of applicable law. We collect only the information necessary to provide, secure, and improve our Services.

2.1 Personal Information You Provide Directly

Account Registration

When you create an account, we collect:

Full legal name

Official email address (typically a government, institutional, or corporate domain email)

Organization or agency name

Job title or role

Username and password (passwords are salted and hashed using bcrypt)

Phone number (optional, for multi-factor authentication)

Payment information (if applicable)

Identity Verification

For law enforcement and certain institutional users, we may collect:

Agency or institutional affiliation documentation

Professional credentials or verification codes

Official correspondence to confirm identity and authorization

Government-issued badge numbers or employee identification numbers (for law enforcement verification purposes only)

We do not collect:

Social Security numbers or national identification numbers

Biometric information such as fingerprints or facial recognition data

Criminal Justice Information Services (CJIS) data, criminal histories, or law enforcement case files

Police report numbers, victim or suspect information

Communications with Us

When you contact us for support, feedback, or inquiries, we may collect:

Email address

Phone number

Content of your messages and correspondence

Any information you choose to provide in your communications

Wallet Submission Data

When you submit crypto wallet intelligence to our platform, we collect:

Crypto wallet addresses (public blockchain identifiers)

Risk indicators, flags, or classifications you assign

Timestamps and metadata about submissions

Your agency or organization identifier and submitter email address

Optional contextual notes (we instruct users not to include PII, case numbers, or investigative details)

This wallet data is not personal information and is used to enhance our intelligence platform and services.

2.2 Information Collected Automatically

Technical Information

When you access our Services, we automatically collect:

IP address and approximate geographic location (derived from IP)

Browser type and version

Operating system and device type

Access timestamps and session duration

Referring URLs and pages visited within our Services

API request logs (for API users)

Security and Fraud Prevention Data

To protect our Services and users, we collect:

Login attempt records and authentication logs

Unusual access patterns or anomalies

Rate limiting and abuse detection metrics

Technologies We Use

We do not use:

Cookies for tracking or analytics

Third-party analytics services (e.g., Google Analytics)

Social media pixels or advertising trackers

We do use:

Session tokens for authentication (temporary, deleted on logout)

Server logs for security monitoring and troubleshooting

Technical cookies strictly necessary for platform functionality (e.g., maintaining your login session)

If we decide to implement analytics or additional tracking technologies in the future, we will update this Privacy Policy and provide appropriate notice and choice mechanisms.

2.3 Information from Third-Party Sources

We may receive limited information from third parties, including:

Email domain verification services to confirm institutional affiliations

Public records or professional databases to verify law enforcement or institutional credentials

Payment processors (if applicable) for billing and transaction processing

We do not purchase personal information from data brokers or marketing lists.

3. How We Use Your Personal Information

We use your personal information for the following legitimate business purposes:

3.1 To Provide and Operate Our Services

Create and manage your user account

Authenticate your identity and authorize access to appropriate features

Enable you to submit and access crypto wallet intelligence

Provide API access to verified customers

Process and respond to your support requests

Facilitate deconfliction and investigative coordination among verified users

3.2 To Improve and Develop Our Services

Enhance our intelligence platform through analysis of submitted wallet data and user interaction patterns

Develop advanced analytical capabilities for crypto wallet risk assessment

Analyze usage patterns to enhance platform features and user experience

Develop new intelligence products and API capabilities

Conduct internal research and development

Note: We improve our platform using aggregated wallet data submitted by users, not your personal account information. The intelligence derived from submitted wallet addresses helps us build better risk detection capabilities for all users.

3.3 To Ensure Security and Prevent Fraud

Detect and prevent unauthorized access, account takeovers, and security threats

Monitor for platform abuse, data scraping, or malicious activity

Investigate and respond to potential violations of our Terms of Service

Maintain audit logs for security and compliance purposes

3.4 To Comply with Legal Obligations

Respond to lawful requests from law enforcement or regulatory authorities

Comply with applicable laws, regulations, and legal processes

Enforce our Terms of Service and other agreements

Protect our rights, property, and safety, and those of our users and the public

3.5 To Communicate with You

Send account-related notifications (e.g., password resets, security alerts)

Provide technical support and respond to inquiries

Notify you of material changes to our Services, Terms of Service, or Privacy Policy

We do not use your personal information for:

Marketing, advertising, or promotional communications (unless you explicitly opt in)

Selling or renting your personal information to third parties

Behavioral profiling or targeted advertising

4. How We Share Your Personal Information

We share your personal information only in the limited circumstances described below. We do not sell, rent, or trade your personal information.

4.1 With Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

Cloud infrastructure and hosting: Amazon Web Services (AWS) for secure, U.S.-based data storage and computing

Email communications: Transactional email service providers for account notifications and support

Security services: Providers of authentication, encryption, and threat detection tools

These service providers are contractually obligated to:

Use your information only to provide services to us

Implement appropriate security measures

Comply with applicable data protection laws

Not disclose or use your information for their own purposes

4.2 API Data Sharing (Aggregated Wallet Intelligence)

We provide aggregated, anonymized crypto wallet intelligence to verified customers (financial institutions, cryptocurrency exchanges, fintech companies) via our API. This intelligence includes:

Wallet risk types and classifications

Flagged wallet categories (e.g., sanctioned entities, fraud indicators)

Statistical patterns and trends

Advanced risk assessments and analytics

What we share via API:

Crypto wallet addresses and associated risk metadata

Aggregated intelligence derived from multiple sources

Transaction pattern analysis and fund flow visualization in some cases

What we do NOT share via API:

Your personal account information (name, email, credentials) except as specified in Section 4.3 for active deconfliction

Investigation-specific details, case numbers, or contextual notes

Any personally identifiable information about suspects, victims, or investigation subjects

Information that could identify which specific user or agency submitted particular wallet data outside of active deconfliction scenarios

Contractual and Technical Safeguards:

API customers are contractually prohibited from attempting to re-identify data sources or users

Rate limiting and access controls prevent bulk data extraction

Regular audits and monitoring ensure compliance with data use restrictions

Anonymization techniques prevent traceability to individual agencies or users except where deconfliction is active

4.3 Active Deconfliction and Case Coordination

When multiple users flag the same crypto wallet address, we facilitate deconfliction and case coordination by sharing limited user information for legitimate investigative and compliance purposes.

Information Shared During Active Deconfliction:

Agency or organization name of the submitter

Email address of the submitter

This information is shared via both our SaaS dashboard and API to facilitate coordination among:

Verified law enforcement agencies investigating the same wallet

Financial institution compliance teams working related cases

Other verified users with a legitimate need for coordination

Privacy Protections:

Information is shared only when there is an active deconfliction (i.e., multiple parties have flagged the same wallet address)

Personal names of individual officers or agents are not disclosed unless the user chooses to include them in their agency profile

No case details, investigative context, or sensitive law enforcement information is shared

Badge numbers and employee identification numbers are never shared and are used solely for internal verification purposes

Users control what contact information is visible in their profile settings

4.4 For Legal Compliance and Protection

We may disclose your personal information if required or permitted by law, including to:

Comply with a subpoena, court order, or other legal process

Respond to lawful requests from government authorities, regulatory agencies, or law enforcement

Enforce our Terms of Service or other agreements

Detect, prevent, or investigate fraud, security incidents, or illegal activity

Protect the rights, property, or safety of Deconflict, our users, or the public

In such cases, we will attempt to notify you unless prohibited by law or if doing so would compromise an investigation.

4.5 In Connection with Business Transactions

If Deconflict is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your personal information may be transferred or disclosed as part of that transaction. In such cases:

We will notify you via email

The acquiring entity will be bound by this Privacy Policy or will provide you with notice and choice regarding any changes

4.6 With Your Consent

We may share your personal information with third parties when you explicitly authorize us to do so.

4.7 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, including:

Statistical reports on platform usage and trends

Anonymized wallet intelligence for research and development

Industry insights and threat intelligence briefings

Once information is de-identified, we may use and disclose it without restriction, provided we do not attempt to re-identify such information.

5. Legal Basis for Processing

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal information based on the following legal grounds:

5.1 Contractual Necessity

Processing is necessary to perform our contract with you (our Terms of Service) and provide the Services you requested.

5.2 Legitimate Interests

We process your information based on our legitimate business interests, including:

Securing and improving our Services

Preventing fraud and abuse

Conducting research and development

Facilitating law enforcement deconfliction and public safety

We balance our legitimate interests against your privacy rights.

5.3 Legal Obligations

We process your information to comply with applicable laws, regulations, and legal processes.

5.4 Consent

In some cases, we process your information based on your explicit consent. When we rely on consent, you have the right to withdraw it at any time by contacting us at contact@deconflict.com.

6. Data Security and Compliance

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information. Deconflict is committed to maintaining the highest standards of data protection and security.

6.1 Compliance Certifications

GDPR Compliance: We are fully compliant with the General Data Protection Regulation (GDPR) for the protection of personal data of individuals in the European Economic Area, United Kingdom, and Switzerland.

SOC 2 Type II Certified: We maintain SOC 2 Type II certification, demonstrating our commitment to maintaining high standards for security, availability, processing integrity, confidentiality, and privacy of customer data.

6.2 Technical Safeguards

Encryption: All data is encrypted in transit using TLS 1.3 (256-bit encryption) and at rest using AES-256 encryption

Secure infrastructure: Data is hosted on Amazon Web Services (AWS) U.S.-based servers with enterprise-grade security controls

Password protection: User passwords are salted and hashed using bcrypt

Multi-factor authentication (MFA): Optional MFA for enhanced account security

Intrusion detection: Automated monitoring for unusual access patterns and security threats

Regular security assessments: Periodic vulnerability scans and penetration testing

6.3 Administrative Safeguards

Role-based access controls: Deconflict personnel access personal information only on a need-to-know basis

Employee training: Regular security awareness and privacy training for all employees

Confidentiality agreements: All personnel are bound by confidentiality obligations

Vendor management: Third-party service providers undergo security assessments and are contractually required to protect your information

6.4 Physical Safeguards

Secure data centers: AWS facilities employ physical security measures including access controls, surveillance, and environmental protections

Controlled access: Deconflict offices restrict physical access to systems containing personal information

6.5 Incident Response

In the event of a data breach affecting your personal information, we will:

Investigate and contain the incident promptly

Notify affected users within 72 hours where legally required

Report the breach to applicable regulatory authorities as required by law

Provide information about the breach and steps you can take to protect yourself

6.6 Limitations

While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of your information.

You are responsible for:

Maintaining the confidentiality of your account credentials

Using strong unique passwords

Enabling multi-factor authentication

Promptly notifying us of any unauthorized access to your account

If you become aware of any security vulnerability or unauthorized access, please contact us immediately at contact@deconflict.com.

7. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes described in this Privacy Policy.

7.1 Account and Registration Data

Active accounts: We retain your registration information while your account is active and you continue to use our Services

Inactive accounts: If your account remains inactive for 24 consecutive months, we may send you a notice and subsequently delete your account and associated personal information

Account deletion: If you request deletion of your account, we will delete your personal information within 30 days, unless we are required to retain it for legal, compliance, or security purposes

7.2 Technical Logs and Security Data

Access logs: IP addresses, login timestamps, and technical logs are retained for 12 months for security monitoring and troubleshooting

Security incident data: Information related to security incidents or abuse investigations may be retained longer as necessary

7.3 Communications and Support Records

Correspondence and support tickets are retained for 24 months to provide continuity of service and address follow-up inquiries.

7.4 Wallet Intelligence Data

Crypto wallet data submitted to our platform is retained indefinitely to support ongoing intelligence operations and API services. This data does not contain personal information and is not subject to the retention limits above. Once wallet data is aggregated and anonymized, it may be retained permanently.

7.5 Legal Holds

If we are subject to a legal obligation, litigation, regulatory investigation, or other legal process, we may retain your information beyond the standard retention periods until the matter is resolved.

7.6 Deletion Upon Request

You may request deletion of your personal information at any time. We will honor such requests unless we have a legal obligation or legitimate business reason to retain the information.

8. International Data Transfers

8.1 Data Storage Location

All personal information collected through our Services is stored and processed in the United States on secure Amazon Web Services (AWS) infrastructure located in U.S. data centers.

8.2 Transfers from the EEA, UK, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, your personal information will be transferred to and processed in the United States. The United States may not provide the same level of data protection as required under EEA, UK, or Swiss law.

To ensure adequate protection of your personal information during international transfers, we rely on the following legal mechanisms:

Standard Contractual Clauses

We use Standard Contractual Clauses (SCCs) approved by the European Commission, UK International Data Transfer Agreement/Addendum, or Swiss-approved transfer mechanisms, as applicable. These are standardized contractual terms that provide appropriate safeguards for the transfer of personal information and ensure that your information receives an adequate level of protection.

Supplementary Measures

In addition to Standard Contractual Clauses, we implement supplementary technical and organizational measures to protect your personal information, including:

Encryption in transit and at rest (256-bit AES encryption)

Role-based access controls limiting who can access personal information

Regular security audits and assessments

Contractual obligations binding our service providers to protect your information

Data minimization practices to collect only necessary information

SOC 2 Type II certification demonstrating our commitment to security and privacy controls

Your Rights

If you are located in the EEA, UK, or Switzerland, you have the right to:

Obtain information about the safeguards we use for international transfers

In certain circumstances, object to the transfer of your personal information

To exercise these rights or for more information about our data transfer practices, please contact us at contact@deconflict.com.

8.3 Transfers from Other Jurisdictions

For users in other jurisdictions outside the EEA, UK, and Switzerland, we process your personal information in accordance with applicable local laws and implement appropriate safeguards as required.

9. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information.

9.1 Rights for All Users

Access: Request access to the personal information we hold about you

Correction: Request correction of inaccurate or incomplete personal information

Deletion: Request deletion of your personal information, subject to certain exceptions

Objection and Restriction: Object to or request restriction of certain processing

9.2 Additional Rights for EEA, UK, and Swiss Users

Data Portability: Receive a copy of your personal information in a structured, machine-readable format

Withdrawal of Consent: Withdraw consent at any time (does not affect lawfulness of prior processing)

Lodge a Complaint: Lodge a complaint with a supervisory authority

9.3 Additional Rights for California Residents

Right to Know: Request disclosure of personal information collected, sources, purposes, and third parties with whom we share it

Right to Delete: Request deletion of your personal information

Right to Correct: Request correction of inaccurate personal information

Right to Opt-Out: We do not sell personal information, but if we ever do, you have the right to opt out

Right to Limit Sensitive Personal Information: We do not collect sensitive personal information as defined by the CCPA

Right to Non-Discrimination: We will not discriminate against you for exercising privacy rights

Authorized Agents: You may designate an authorized agent to submit requests on your behalf

9.4 Additional Rights for Other U.S. State Residents

If you are a resident of Virginia, Colorado, Connecticut, Utah, or other states with comprehensive privacy laws, you may have similar rights to those described above.

9.5 How to Exercise Your Rights

To exercise any privacy rights, please contact us at:

Email: contact@deconflict.com

Subject Line: Privacy Rights Request

Mail: Deconflict, Inc., 8 The Green STE A, Dover, DE 19901, United States

Please include:

Your full name

Email address associated with your account

Description of the specific right(s) you wish to exercise

9.6 Verification Process

To protect your privacy and security, we will verify your identity before fulfilling your request. We will respond to verified requests within the timeframes required by applicable law, typically within 30-45 days.

9.7 Appeals

If we deny your privacy request, you have the right to appeal. Contact us at contact@deconflict.com with “Privacy Rights Appeal” in the subject line.

10. Do Not Track and Global Privacy Control

10.1 Do Not Track

Our Services do not respond to Do Not Track (DNT) signals as there is no industry consensus on how to respond to them.

10.2 Global Privacy Control

If we detect a Global Privacy Control (GPC) signal from your browser, we will treat it as a request to opt out of the sale or sharing of your personal information, to the extent required by law. Learn more at https://globalprivacycontrol.org/.

11. Children’s Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children under 13 years of age.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at contact@deconflict.com.

If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes:

We will update the “Last Updated” date at the top of this Privacy Policy

We will post the updated Privacy Policy on our website

We will notify you via email for material changes

We will provide prominent notice on our website for significant changes

Your continued use of our Services after changes become effective constitutes acceptance of the updated Privacy Policy. If you do not agree with the changes, you must stop using our Services and may request deletion of your account.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Deconflict, Inc.

8 The Green STE A

Dover, DE 19901

United States

Email: contact@deconflict.com

Subject Line: Privacy Inquiry

For Data Privacy Framework inquiries (EEA, UK, Swiss users):

Email: contact@deconflict.com

Subject Line: Data Privacy Framework Inquiry

For Privacy Rights Requests:

Email: contact@deconflict.com

Subject Line: Privacy Rights Request

We will respond to your inquiry within 30 days.

14. Notice at Collection for California and Other U.S. State Residents

This section provides additional disclosures required by the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and similar state privacy laws.

14.1 Categories of Personal Information Collected

Identifiers

Examples: Name, email, username, organization, IP address

Sources: Directly from you; automatically

Business Purposes: Account management, authentication, security, deconfliction

Third Parties: Service providers (AWS, email); verified users during active deconfliction

Professional Information

Examples: Job title, agency affiliation, credentials, badge numbers

Sources: Directly from you; verification sources

Business Purposes: Identity verification, access control

Third Parties: Service providers

Internet Activity

Examples: IP, browser, access logs, API usage

Sources: Automatically

Business Purposes: Security, platform improvement

Third Parties: Service providers (AWS, security tools)

Commercial Information

Examples: Account status, subscription info

Sources: Directly from you; internal

Business Purposes: Service provision, billing

Third Parties: Service providers

14.2 Sensitive Personal Information

We collect government-issued badge numbers or employee identification numbers solely for law enforcement verification purposes. This information is never shared with third parties and is used only for internal identity verification. We do not collect other categories of sensitive personal information as defined by the CCPA/CPRA (Social Security numbers, financial account credentials, precise geolocation, biometric information, health information, or information about sex life or sexual orientation).

14.3 Sale or Sharing of Personal Information

We do not “sell” or “share” personal information as defined by the CCPA/CPRA. We have not sold or shared personal information in the preceding 12 months, and we do not have actual knowledge of any sale or sharing of personal information of minors under 16 years of age.

14.4 Retention Periods

We retain personal information for the periods described in Section 7 of this Privacy Policy.

14.5 Automated Decision-Making

We use analytical tools to generate crypto wallet risk scores based on submitted wallet data. These processes do not produce legal or similarly significant effects concerning you as a registered user.

14.6 Right to Opt Out

If we ever engage in the sale or sharing of personal information, we will provide a clear link titled “Do Not Sell or Share My Personal Information” on our website.

14.7 Financial Incentive Programs

We do not offer financial incentive programs that involve the collection, retention, or sale of personal information.

15. Acknowledgment

By using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

Last Updated: May 1, 2025